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NFC: Fw: [Updates] TELL EPA THAT IT MUST INCLUDE FLOWS IN THE NEW WATER QUALITY REGULATIONS!

TELL EPA THAT IT MUST INCLUDE FLOWS IN THE NEW WATER QUALITY REGULATIONS!
TIME IS RUNNING OUT!

The public comment period on EPA’s proposed water quality restoration
plans
(TMDLs) closes on THURSDAY, JANUARY 20, 2000. MAKE YOURSELF HEARD!

Overall, EPA’s draft TMDL regulations are good in their coverage of
non-point source pollutants and their requirement that states list all
sources and causes of impairment to water quality, including all
POLLUTION,
not just POLLUTANTS. This is important because the definition of
POLLUTION
includes FLOW – the amount of water left in the river – whereas
POLLUTANTS
does not.

BUT the proposed regulations only require water quality restoration plans
(TMDLs) for water bodies impaired by POLLUTANTS, not POLLUTION. This goes
against the intent of the Clean Water Act.

PLEASE TELL EPA THAT ALL POLLUTION MUST BE ADDRESSED BY TMDLS IF THEY ARE
TO
GENERATE SOUND WATER MANAGEMENT POLICY.

KEY MESSAGES:

·	Listing all sources of pollution and causes of impairment of water
quality
is a step in the right direction, but the TMDL program must REMEDY all
pollution as well.
·	The Clean Water Act requires that all sources of pollution, including
flows, be addressed by TMDLs.
·	If TMDLs do not address the physical and biological integrity of the
waters, it will become a piecemeal and illogical approach to water
quality
restoration and could result in worse water quality and further
diminished
flows over time.
·	The very carefully balanced political body, the Federal Advisory
Committee
on TMDLs, set up by EPA to advise it on just such problems, recommended
to
EPA that flow and other pollution impairment be listed AND addressed by
TMDLs. What more does EPA need??
·	Ever-shrinking flows are causing point source and other discharges to
change treatment methods at great expense. This is unfair to industry,
local
governments, and others who are trying to comply with the law.

To see a sample letter, see http://www.amrivers.org/tmdlletter.html. Use
this letter or write your own letter and send it to:
Comment Clerk for the TMDL Program Rule
Water Docket (W-98-31)
Environmental Protection Agency
401 M Street, SW
Washington, DC 20460

To see a fact sheet on TMDLs, visit
http://www.amrivers.org/tmdlfactsheet.html.
To read American Rivers’ comments to EPA on the proposed TMDLs, visit
http://www.amrivers.org/tmdlcomments.html.

For more information on TMDLs, visit the Clean Water Network at
www.cwn.org
or the EPA’s website on TMDLs at http://www.epa.gov/owow/tmdl/index.html.

********************
Suzy McDowell
Outreach Coordinator
American Rivers
1025 Vermont Ave, NW, #720
Washington, DC 20005
202-347-7550 x3040
smcdowell at amrivers_org